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213. We cannot and need not go as far as the
majority had gone in Bank Mellat [Bank
Mellat v. Her Majesty's Treasury (No. 2), 2014
AC 700 : (2013) 3 WLR 179 : 2013 UKSC 39] .
UK has a statute where standards of procedure
for judicial review are set out and the majority
decision was on the application of those
standards. But even by our own standards, we
are obliged to see if there were less intrusive
measures available and whether RBI has at
least considered these alternatives. On the
question of availability of alternatives, the July
2018 Report of the European Union Parliament
(titled "Cryptocurrencies and Blockchain") is
relied upon by Shri Ashim Sood. The relevant
portion (in Para 5.4) reads as follows:
- 72 -
NC: 2024:KHC-D:6912
WP No. 107496 of 2023 and Connected
matters
"In this respect we also note that some
cryptocurrencies that are now on the market,
such as Dash and Monero, are fully
anonymous, whereas others, such as Bitcoin
and the like are pseudo-anonymous, basically
meaning that if great effort is made and
complex techniques are deployed, it is possible
for authorities to find out users' identities.
These fully anonymous cryptocurrencies are
designed to stay in the dark and outside of the
scope of authorities. After AMLD5 (Fifth Anti-
Money Laundering Directive of the European
Union) this will no longer be possible to the
fullest extent : the cryptocurrency users that
want to convert their cryptocurrency into fiat
currency via a virtual currency exchange or
hold their portfolio via a custodian wallet
provider, will be subject to customer due
diligence. But, as aforementioned, there is still
a whole world outside of these new obliged
entities under AMLD5. It goes without saying
that this may sound particularly interesting for
criminals seeking for new ways to launder
money, finance terrorists or evade taxes. If a
legislator does not want to outright ban these
cryptocurrencies -- and for not imposing such a
ban a good argument is that cash is also fully
anonymous and lawful -- the only way to find
out who uses them is to require users to
register mandatorily. For reasons of
proportionality it could then be considered to
make the registration subject to a materiality
threshold."